THE STATE BAR COURT
OF THE STATE OF CALIFORNIA
HEARING DEPARTMENT - LOS ANGELES

In the Matter ofGRAHAM EDWARD BERRYNo.128503A Member of the State Bar
))))))))))))))))) Case No.: 99-0-12791ATTACHMENT A TO SUBPOENA
DUCES TECUM ISSUES BY PARTY RESPONDENT GRAHAM E. BERRY AND BEING HIS
FIRST DEMAND TO PRODUCE DOCUMENTS, RECORDS, BOOKS OR THINGS DIRECTED
AT THE CUSTODIAN (S) OF DOCUMENTS ELLIOT J. ABELSON AND THE LAW
OFFICES OF ELLIOT J. ABELSON (Numbered 1- 33 )

RESPONDENT, GRAHAM EDWARD BERRY ("Berry"), hereby propounds his Demand
to Produce Documents, Records, Books or Things, Set No. One (Numbers
1- 33), to the Custodian (s) of Documents of Elliot J. Abelson and the
Law Offices of Elliot J.Abelson ("You" as defined hereunder). This
Request for Documents, Records, Books or Things is propounded, inter
alia, pursuant to C.C.P. §§ 94, 1011(a) - 1013 (a), 1987.3, 2016 to
2031 (specifically § 2020 (d)), Cal. Evidence Code § 1560 (e) and
Rules 151 to 187 of the Rules of Procedure of the State Bar of
California. Inspection and copying of the documents, records, books
and things produced in response to this request shall take place on
August 23, 2001, at 10:00 a.m. at the offices of Elliot J.Abelson,
8491 West Sunset Boulevard, Suite 1100, Los Angeles, CA 90069, or as
may be noticed by amended notice and/or a letter agreement signed by
both the propounding and responding party (s); e.g., to adopt the
provisions of C.C.P. 2020 (d) (4).

DEFINITIONS AND EXPLANATIONS

A. "Document" and or "document" shall in all instances mean the
original and duplicate (s), including without limitation carbon copies
or photo (Xerox) copies, of each "writing" or other tangible thing
within the meaning of C.C.P. § 2031, California Evidence Code § 250
and Federal Rule of Evidence 1001(1).

B. "Document" and or "document", in addition to the definitions above
[and in accordance with the definitions, policies, bulletins, customs,
practices and other directives of the Church of Scientology as defined
hereunder], without limitation, shall also include any and all Red Box

C. "Communication" or "Comm" shall include any transmission of
information from one person or entity to another person or entity,
whether by document or otherwise, including, without limitation, by
personal meeting, telephone, radio, video, modem, telegraph, teletype,
electronic mail or other transmission, teleconference, or other mode
of communication.

D. "And" as well as "or" shall be construed either conjunctively or
disjunctively so as to bring within the scope of this request any
document that might otherwise be construed outside its scope.

E. As used herein, the singular of any word or phrase includes the
plural and the plural includes the singular.

H. The terms "Elliot Abelson", "you" or "your" as used herein shall
mean the responding party herein, the custodian(s) of documents, books
and records for Elliot J. Abelson and the Law Offices of Elliot J.
Abelson ("Abelson") and shall include his/her/its present and former
partners, associates, assistants, handlers, employees and
representatives and every Document Request herein is directed to "you"
and /or "your" as so defined, unless expressly indicated otherwise.

I. The term "Church of Scientology" includes all corporations and
Churches of Scientology and Missions thereof including, but not
limited to, Sea Org Reserves, Ltd.; the Sea Organization ('the Sea
Org"); the Commodores Messenger Organization International ("CMO
Int."); the Commodores Messenger Organization ("CMO"); Church of
Spiritual Technology ("CST"); Religious Technology Center ("RTC");
Church of Scientology International ("CSI"); Building Management
Services ("BMS"); Golden Era Studios; Gold; Gold Base; Author
Services; Inc., ("ASI"); The L. Ron Hubbard Library; and
"Administrative" organizations including, but not limited to,
Continental Liaison Offices (CFOs); INCOMM; "INT Management"; The
International Justice Chief; The Finance Dictator; The Finance Police;
"The International
Finance Police Network"; " The Finance Banking Officer (FBO) Network;
The Director of Special Affairs ("DSA") Network and each of their legal owners,
beneficial owners, managing agents, special directors, directors,
trustees, trustors, beneficiaries, officers, employees, staffers,
volunteers, attorneys, agents, service providers (including, but not
limited to, storage facilities, safe deposit boxes and storage vaults
["nuclear bomb proof" or otherwise]) and representatives including,
but not limited to, those which are the subject of any Internal
Revenue Service single or group section 501(c) (3) exemption.

J. (a) If any documents requested herein are withheld from production
on grounds of privilege, please provide with your response a complete
privilege log including for each such document: (i) the date and
number of pages of the document; (ii) its title (if any); (iii) its
general subject matter; (iv) the identity of attachments or appendices
to the document; (v) the name and address of each person who received
a copy thereof; (vi) the name and address of each person to whom the
document was distributed, shown, described to or explained; (vii) the
name and address of the person or persons by whom it was written;
(viii) its present custodian and/or location; (ix) the particular
privilege claimed and a full description of the factual grounds upon
which it is being withheld; (x) the relationship of the author to each
addressee and each person who received, was shown, or was informed of
the contents of the document; and (xi) all facts which, objectively
viewed, show or may tend to show a waiver of the privilege asserted,
and

(b) In connection with any assertions of privilege and /or attorney
work product herein it is, and will be, Respondent's contention and
argument that California Evidence Code section 956 (the crime-fraud
exception) applies and prevails.

K. When this Document Request calls for a document which, while known
to you is not, or is no longer in, your possession, custody or
control, you shall identify, in your written response hereto, the
document's present location(s) and custodian(s), or otherwise its last
known location(s) and custodian(s) and the identity of the person(s)
or entity(s) most likely to have relevant and responsive knowledge
and/or information.

L. If any document called for by this Document Request has been
destroyed, lost, altered, discarded, transferred elsewhere, or stored
elsewhere, please include in your written response separately for each
such document: (i) the identity of all authors, addressees and
recipients; (ii) the date, subject matter, and number of pages of the
document; (iii) a description of any attachment or appendices to the
document; (iv) the names and identification of all persons to whom the
document was distributed, shown or explained; (v) the date when it was
destroyed, lost, altered, transferred, stored or discarded, the manner
and circumstances in which same occurred, and the reason for same;
(vi) the names and addresses of all persons who authorized or
effectuated such conduct; and (vii) the names and addresses of all
persons and/or entities who/which might still have a copy of the
document or any part of it,(viii) the current location and custodian
of the document and the identity of all managing agents and custodians
of document(s) thereat.

N. The attention of responding party(s) herein is/are directed at the
"meet and confer" provisions of State Bar Rule of Procedure Rule 185
and C.C.P.§ 2023 (9).

REQUEST FOR PRODUCTION OF DOCUMENTS

1. All documents and communications that refer to or constitute any
retainer or employment agreement between you and the Church of
Scientology.

2. All documents and communications [and in addition to the definition
of documents above, in accordance with the following words meanings,
definitions, policies, bulletins, customs, practices and other
directives of the Church of Scientology] that refer or relate to your
relationship to all or any of the corporations and Churches of
Scientology including, but not limited to, the org board and/or
command chart(s) that show your relationship(s) to the Church of
Scientology, OSA Int, OSA US, CST, RTC, CSI, "Flag", ASI,
CMO Int. and the Watch Dog Committee.

5. All documents and communications [and in addition to the
definition of documents above, in accordance with the following words
meanings, definitions, policies, bulletins, customs, practices and
other directives of the Church of Scientology] that refer or relate to
bonuses you have received as a result of any [good result] "up"
statistics, as well as any other forms of monetary compensation over
and above standard pay that resulted as a reward for doing your job.

7. All documents and communications [and in addition to the
definition of documents above, in accordance with the following words
meanings, definitions, policies, bulletins, customs, practices and
other directives of the Church of Scientology] that refer or relate to
the command chart(s) on which the Church of Scientology; CST; the Sea
Org; Sea Org Reserves, Ltd.; CMO Int.; CMO; RTC; BMS; CSI; CSI OSA;
the OSA Legal Unit; Moxon & Kobrin; you and/or the Watch Dog Committee
are identified.

8. All documents and communications [and in addition to the definition
of documents above, in accordance with the following words meanings,
definitions, policies, bulletins, customs, practices and other
directives of the Church of Scientology] that refer or relate to
Evals, Strategic Plans, Tactical Plans, programs and projects on which
you and/or the attorney unit are named or have targets.

9. All documents and communications [and in addition to the
definition of documents above, in accordance with the following words
meanings, definitions, policies, bulletins, customs, practices and
other directives of the Church of Scientology] that refer or relate to
Keith Henson, Riverside District Attorney Grover Trask, Deputy DA
Robert Schwarz, Alan C. Oberstein, Gerald Feffer, Samuel D. Rosen,
Hon. Robert H.Wallerstein, Alternative Resolution Centers, Graham
Berry, and James Harr.

10. All documents and communications [and in addition to the
definition of documents above, in accordance with the following words
meanings, definitions, policies, bulletins, customs, practices and
other directives of the Church of Scientology] that refer or relate to
those two draft declarations, relating to Graham Berry, and presented
for execution to Robert Vaughan Young and Stacy Brooks Young in or
about July 8-16,1994.)

11. All documents and communications including, but not limited to,
those that refer or relate to, or concern in any way, Graham Berry and
Associates including,, but not limited to, those relating
to or mentioning Berry; Lewis, D'Amato, Brisbois & Bisgaard, LLP;
Musick, Peeler & Garret, LLP; Law Offices of Graham E. Berry; Berry,
Lewis, Scali & Stojkovic and any of their current of former partners,
associates or employees.

13. All documents and communications [and in addition to the
definition of documents above; in accordance with the following words
meanings, definitions, policies, bulletins, customs, practices and
other directives of the Church of Scientology] that refer or relate to
payments made to or for any and all persons, lawyers, businesses,
private investigators, investigators, surveillance personnel and
surveillance, in connection with or relating to Graham Berry and
Associates.

14. All documents and communications [and in addition to the
definition of documents above, in accordance with the following words
meanings, definitions, policies, bulletins, customs, practices and
other directives of the Church of Scientology] that refer or relate to
payments made to or for, services provided to or for, benefits
given/provided to and for, and agreements made with or for or relating
to: Vicki Azneran; Richard Azneran; Phoenix Investigations; Garry
Scarff;

15. All documents and communications [and in addition to the
definition of documents above, in accordance with the following words
meanings, definitions, policies, bulletins, customs, practices and
other directives of the Church of Scientology] that refer or relate to
the Church of Scientology internal guiding policies, advices, special
tech and dispatches relating to Graham Berry and Associates.

17. All documents and communications [and in addition to the
definition of documents above, in accordance with the following words
meanings, definitions, policies, bulletins, customs, practices and
other directives of the Church of Scientology] that refer or relate to
sources of funding for OSA ops or your activities, representation
and/or cycles of action against or relating to Graham Berry and/or
Associates including but not limited to: the International Association
of Scientologists ("IAS"); any World Institute of Scientology
Enterprises ("WISE") entity or member (including any documents
relating to your membership of WISE and IAS); and any Church of
Scientology entity or member(s).

18. All documents and communications [and in addition to the
definition of documents above, in accordance with the following words
meanings, definitions, policies, bulletins, customs, practices and
other directives of the Church of Scientology] that refer or relate to
the Church of Scientology International, Moxon, Bowles, Farny and/or
Ingram "investigation" of Graham Berry that commenced in late 1993 and
early 1994 including, but not limited to, all photographs, phone tap
logs, audio and video recording machines or devices, and all other
related documents, books, records and things.

19. All documents [and in addition to the definition of documents
above, in accordance with the following words meanings, definitions,
policies, bulletins, customs, practices and other directives of the
Church of Scientology] that refer or relate to communications with any
international, national, federal, state or local government entity,
supervisory and/or professional organization (including national
security [e.g., the German government Office(s) for the Protection of
the Constitution], security, law enforcement entities and their
representatives) bar associations and law societies, professional
organizations, media, entity(s) or person(s) relating to Graham Berry
and Associates.

20. All documents and communications [and in addition to the
definition of documents above, in accordance with the following words
meanings, definitions, policies, bulletins, customs, practices and
other directives of the Church of Scientology] that refer or relate to
the legal and beneficial owners and/or ownership of the Church of
Spiritual Technology ("CST"), its principals, trustees, directors,
officers, premises, staffers, securities, records, property and
assets.

21. All documents and communications [and in addition to the
definition of documents above, in accordance with the following words
meanings, definitions, policies, bulletins, customs, practices and
other directives of the Church of Scientology] that refer or relate to
operational documents on the destruction of Graham Berry, Graham Berry
and Associates, the Law Offices of Graham E. Berry and Berry, Lewis,
Scali & Stojkovic.

22. All documents and communications that refer or relate to the
application and processing of Michael Pattinson's application for
permanent residency ("green card") status in the United States.

23. All documents and communications [and in addition to the
definition of documents above, in accordance with the following words
meanings, definitions, policies, bulletins, customs, practices and
other directives of the Church of Scientology] that refer or relate to
Plan(s) for the Erlich raid, Lerma raid, Wollersheim raid, FactNet
raid, Penny raid.

24. All documents and communications of the Church of Scientology that
refer or relate to various Internet nom-de-plumes including, but not
limited to, nobody @replay.com;
Nobody@huge.cajones.com; wgert@loop.com, which mention the name Berry
or Graham Berry and all Internet or newsgroup postings you have made,
either under your own name or a nom-de-plume, and/or in association or
supervision of others, and which mention the names Graham and Berry,
and/or Cipriano, Hurtado and Apodaca including, but not limited to,
the ARS Bigots Home Page.

26. All documents and communications that refer or relate to all
motions and requests for sanctions, costs and/or contempt, made by you
or any other attorney representing the Church of Scientology and/or
any of its members, employees and related entities, against Graham
Berry.

32.All documents and communications that refer or relate to the Casey
Hill v. Church of Scientology and the Ontario Operation Snow White
litigation, in the Dominion of Canada.

33. All documents and communications that refer or relate to Jeavons
v. Church of Scientology International, LASC Case No.BC 207363

DATED: July 31, 2001
Respectfully Submitted,

Graham E. Berry

PROOF OF MAIL SERVICE

I, Graham E.Berry, certify and declare as follows:

I am over the age of 18 years, I am an officer of this court
and I am the respondent herein.

On July 31, 2001, I mail served the following documents
described as

SUBPOENA DUCES TECUM AND ATTACHMENT A TO SUBPOENA DUCES TECUM ISSUES
BY PARTY-RESPONDENT GRAHAM E. BERRY AND BEING HIS FIRST DEMAND TO
PRODUCE DOCUMENTS, RECORDS, BOOKS OR THINGS DIRECTED AT THE CUSTODIAN
(s) OF DOCUMENTS OF ELLIOT ABELSON, et al. (Numbered 1- 33).

On the interested parties in this action addressed as follows:

By placing one copy in an envelope and personally
depositing it at a United State Postal Service facility, on the date
shown below, first class postage affixed and addressed to:

I declare under penalty of perjury under the laws of the United
States and the State of California that the foregoing is true and correct.

Executed on this 31st day of July 2001, at Los Angeles, California.

__________________________
Graham E. Berry

PROOF OF PERSONAL SERVICE

I, Graham E.Berry, certify and declare as follows:

I am over the age of 18 years, I am an officer of this court
and I am the respondent herein.

On July 25, 2001, I personally served the following
documents described as:

SUBPOENA DUCES TECUM AND ATTACHMENT A TO SUBPOENA DUCES TECUM ISSUES
BY PARTY-RESPONDENT GRAHAM E. BERRY AND BEING HIS FIRST DEMAND TO
PRODUCE DOCUMENTS, RECORDS, BOOKS OR THINGS DIRECTED AT THE CUSTODIAN
(s) OF DOCUMENTS OF ELLIOT ABELSON, et al. (Numbered 1- 33).

On the responding entity and/or person(s) named therein,
addressed as follows:

The Custodian of Documents for Elliot Abelson and the Law Offices of
Elliot Abelson, 8491 West Sunset Boulevard, Suite 1100,
Los Angeles, CA 90069

A copy of such addressed being attached hereto as Exhibit A.

By leaving the papers at the officially designated offices of Elliot
J. Abelson, in an envelope clearly labeled to identify the attorneys
being served, with a receptionist and/or with a person having charge
thereof, and requesting that person to immediately advise the
addressees with notice of its receipt. CCP § 1011(a).

I declare under penalty of perjury under the laws of the
United States and the State of

California that the foregoing is true and correct.

Executed on this 31st day of July 2001, at Los Angeles, California.

__________________________
Graham E. Berry

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